The U.S. Department of Agriculture has filed a 10-page complaint
against Santa Cruz Biotechnology alleging numerous violations of the
federal animal welfare act.

The complaint, dated July 19, lists incidents stemming from inspections
in 2007 through May of this year, including problems with the handling
of animals, inadequate veterinary care, improper food and unqualified
personnel.

The USDA's complaint details a lengthy history of problems found by
inspectors at the Delaware Avenue laboratory, which the agency's
Animal and Plant Health Inspection Service launched an investigation
into in 2010 after two inspections that year turned up a dozen sick or
injured goats.

A representative from the company could not be reached to comment
Monday.

Santa Cruz Biotechnology also was cited in February 2011 for
noncompliance involving blood collection rules, three repeated citations
and one goat that was unable to walk. Medical records for sick animals
were found to be incomplete.

More recently, federal inspectors in March found that the facility had
one staff veterinarian tasked with caring for 10,000 goats, about 6,000
rabbits and an undetermined number of cattle and horses.

During that inspection, as well as follow-ups in April and May,
inspectors found goats with ailments ranging from an untreated broken
leg, serious skin conditions and low body weight. One goat died of
untreated pneumonia during an inspection on May.

The company is required to file a response to the USDA's complaint
within a specified time frame, or the agency will consider failure to
response to constitute an admission of all allegations contained in the
complaint. An oral hearing likely will be conducted if and after the
company responds.

David Sacks, a spokesman for the USDA, said the company could face a
penalty of up to $10,000 per violation. Determination of fines is based
on multiple factors, including how egregious the violation is, the size
of the facility, the facility's prior penalty history and whether the
company made a good faith effort to correct the problem.

Animal rights activist Michael Budkie, executive director of Ohio-based
Stop Animal Exploitation Now, said he was happy to see the USDA taking
action.

"We are very pleased that the USDA is moving forward with a major case
against Santa Cruz Biotech," Budkie said. "The facility deserves the
largest fine possible under the animal welfare act."

Budkie's organization monitors hundreds of animal research labs across
the country and Santa Cruz Biotech has long been on his radar.